INTERNAL INFORMATION SYSTEM

MERLIN Properties SOCIMI, S.A. (“MERLIN”) hopes that both its conduct, that of its subsidiaries (the “Affiliates” and, together with Merlin, the “Group” or the “MERLIN Group”) as well as that of its employees, managers and administrators within the Grupo MERLIN (the “Professionals”) responds and complies, in addition to current legislation and its corporate governance system, to generally accepted ethical and social responsibility principles.


The Ethic Channel of MERLIN and its subsidiaries is a tool whose objective is to provide a safe, anonymous and confidential means for anyone to report any irregularity or non-compliance related to bad practices within the organization, committed in relation to the requirements that emanate from both the Code of Conduct, the responsibilities of the Company’s Criminal Risk Prevention Model, the values ​​and principles of its Code of Conduct and current legislation on Criminal Liability of Legal Entities as well as in the field of workplace bullying.


MERLIN wants to be diligent in protecting whistleblowers. In this sense, MERLIN has outsourced the management of the Ethical Channel with BDO to guarantee the maximum confidentiality regarding the identity of the informant, as well as compliance with current legislation in the treatment of communications received.


Any third party that is related to MERLIN and that has reasonable indications of an Irregularity (an “Informant”) may notify MERLIN through this Channel. MERLIN Professionals will be, in any case, obliged to report any reasonable indication of any Irregularity.



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